Lynda Harris | March 21, 2022
The Plain Language Bill is being considered by the New Zealand Parliament. If the Bill becomes law, it will require all government agencies to communicate in plain language.
Read our submission to the Governance and Administration Select Committee below.
If you’d like to send a submission supporting the Plain Language Bill, you can use our template, which has starter prompts to get you thinking. Submissions are due by 31 March 2022.
We appreciate the opportunity to share our support for, and feedback on, the Plain Language Bill. This submission includes our overall support for the intent of the Bill, along with comment on specific clauses, and some recommendations for you to consider.
We support the intent of the Plain Language Bill for the following key reasons:
Clear language is necessary for people to:
Given its critical importance in a transparent and fair democracy, clear language cannot be left to chance. Over 31 years as a plain language consultancy, we have seen ample evidence of what happens when New Zealand government agencies are left to decide what matters in their approach to written communication.
Agencies that communicate effectively do so usually as the result of motivated individuals who take personal responsibility for ensuring public communications are plain. All too often, quality slips badly when those individuals leave and their influence is no longer felt.
Our work with almost every government agency over many years has given us an in-depth understanding of the colossal waste of money and time that results from un-plain website information, government forms, and explanatory leaflets. Government agencies spend millions of dollars annually responding to questions, clarifying information, following up on poorly completed forms — and on calming upset members of the public who cannot find what they need or understand the information once they find it.
One project we completed several years ago saved an average $1.5 million annually by revising a form that had close to a 100% error rate.
Occasionally we work with government managers to calculate how much a particular document costs to produce. We count the average hourly rates of each staff member involved, how many times they worked on the document, why they were involved, and how much time they spent. The results are usually shocking to those involved and often spur an initiative to improve writing quality.
Improvements can be dramatic with much time saved and a better finished result. But equally, these good results are often short-lived if the individual concerned moves on or simply loses enthusiasm to persist in the face of other pressures.
We particularly support and wish to comment on the following aspects of the Bill.
Appointing a plain language officer is the first step in creating a focus on, and accountability for, plain language within an organisation. It sends the message that writing clearly:
This position fits within the scope of a Quality Improvement Officer, tasked with improving organisational effectiveness and efficiency. We would expect the position of plain language officer to be properly scoped according to the size of the agency, with it being a full-time or at least half-time position in larger agencies.
Appointing a plain language officer creates a formal mechanism to expect and promote plain language, rather than relying on the goodwill and enthusiasm of a few who have no mandate or resources to create change.
Reporting on an agency’s compliance with the Act, and on their ongoing initiatives and results, is key to fulfilling the intent of a Plain Language Bill. Without formal expectations on Chief Executives, devolving to plain language officers, best intentions will not produce the necessary change.
We believe the Bill could be strengthened by the following:
The definition below, found on the International Plain Language Federation website, is a vital part of conveying the fundamental goal of this Bill.
A communication is in plain language if its wording, structure, and design are so clear that the intended readers can easily find what they need, understand what they find, and use that information.
Agencies and their staff must have a very clear understanding of what they are required to do. And this understanding should be standardised across the government service. For simplicity, consistency, and ease of administration, we recommend that government agencies are given a minimum writing standard that covers the key aspects of plain language.
The Write Plain Language Standard, used already by many government agencies and other organisations internationally, is freely available under a Creative Commons licence.
To support the reporting and accountability provisions already in the Bill, we strongly recommend that the Public Service Commissioner publish a consolidated annual report that covers the degree of compliance, and gains in efficacy and effectiveness, from each government agency.
Such a report would be strong motivation for each agency, their Chief Executive, and plain language officer, to give plain language the time and resources needed.
Consequences for non-compliance usually increase the chance of success. Conversely, a requirement with no consequences for failure to meet it is likely to be ignored or buried under the weight of other ‘louder’ expectations. We urge you to consider simple consequences that will help ensure the intent of the bill is met.
Lastly, we applaud and strongly support the signal that this Bill is only the start of a wider initiative to make plain language a requirement for all government communication, both public and private. When plain language is a requirement for all types of government writing, businesses will follow government’s example. New Zealand will have a fairer, more equitable society as a result.
Plain English must become the standard for all official public and private communication in New Zealand. This Bill requires the New Zealand Government to start making that happen.
Read the rest of the Bill on the Parliament website
We also wish to make an oral submission.
CEO, Write Limited
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